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Category: SARS Published Rulings

BPR251 (ITA) – Cancellation of reinsurance agreement (“Person”, “company”, “equity share” definitions, section 24BA, section 41(1), section 42, paragraphs 10(b)(ii), 20, 31(1), 35 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR251 (ITA) - Cancellation of reinsurance agreement (“Person”, “company”, "equity share" definitions, section 24BA, section 41(1), section 42, paragraphs 10(b)(ii), 20, 31(1), 35 of Eighth Schedule)

BPR252 (ITA) – ​Donations tax and capital gains tax consequences of the part waiver of a loan and reduction of the interest rate (Section 54, section 58, paragraph 12A of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR252 (ITA) - ​Donations tax and capital gains tax consequences of the part waiver of a loan and reduction of the interest rate (Section 54, section 58, paragraph 12A of Eighth Schedule)

BPR253 (ITA) – Donations tax consequences of a transaction to introduce a BEE shareholder into a group (“Donation” definition, section 54, section 55(1), section 57, section 58)

Posted on January 23, 2019 by admin_kmos
Posted in BPR253 (ITA) - Donations tax consequences of a transaction to introduce a BEE shareholder into a group ("Donation" definition, section 54, section 55(1), section 57, section 58)

BPR46 (ITA) – Accrual of an unclaimed retirement fund (lump sum) benefit (“Gross income” definition, paragraph 2 of Fourth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR46 (ITA) - Accrual of an unclaimed retirement fund (lump sum) benefit (“Gross income” definition, paragraph 2 of Fourth Schedule)

BPR47 (ITA) – ​Agency income earned by a controlled foreign company to be excluded from its net income (Section 9D(2A), section 9D(9)(b)(ii)(cc)(C))

Posted on January 23, 2019 by admin_kmos
Posted in BPR47 (ITA) - ​Agency income earned by a controlled foreign company to be excluded from its net income (Section 9D(2A), section 9D(9)(b)(ii)(cc)(C))

BPR48 (ITA) – ​Deeming a place of business to be a ‘foreign business establishment’ as envisaged in section 9D(1) (Section 9D(1), section 9D(10)(a)(i))

Posted on January 23, 2019 by admin_kmos
Posted in BPR48 (ITA) - ​(The guidance contained in this ruling is affected by subsequent law changes) - 'foreign business establishment' as envisaged in section 9D(1)

BPR49 (ITA) – Nature of proceeds received for the lease of property in terms of a 99 year lease (Paragraph 2 of Eighth Schedule)

Posted on January 23, 2019 by admin_kmos
Posted in BPR49 (ITA) - (The guidance contained in this ruling is affected by subsequent case law) - proceeds received in terms of a 99 year lease

BPR50 (ITA) – Cash grants made by an employer to share-incentive scheme trusts and their deductibility for tax purposes (Section 11(a), section 23H)

Posted on January 23, 2019 by admin_kmos
Posted in BPR50 (ITA) - Cash grants made by an employer to share-incentive scheme trusts and their deductibility for tax purposes (Section 11(a), section 23H)

BPR51 (ITA) – ​Environmental expenditure allowances (Section 37B)

Posted on January 23, 2019 by admin_kmos
Posted in BPR51 (ITA) - ​Environmental expenditure allowances (Section 37B)

BPR52 (ITA) – Repatriation of profits in the form of foreign dividends paid by a foreign subsidiary to a resident company which was previously exempt from income tax (Section 10(1)(k)(ii)(dd))

Posted on January 23, 2019 by admin_kmos
Posted in BPR52 (ITA) - (The guidance contained in this ruling may be affected by subsequent law changes) Repatriation of foreign dividends paid to a resident company which was previously exempt

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